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sent a notice of deficiency for 1995. The notice proposed a
deficiency of $65,975 and an addition to tax of $16,494 for late
filing, plus an accuracy-related penalty of $13,195.07. The
notice was sent by certified mail to petitioner at the Woodside
address, and a copy was sent to Stone in Henry, Virginia. Stone
received the notice of deficiency but did not inform petitioner,
believing that some contacts she had made with the Office of the
Taxpayer Advocate precluded further action by the IRS.
Petitioner did not file a petition with this Court with
respect to the 1995 deficiency during the time permitted, which
expired November 17, 1999. On February 7, 2000, the deficiency
for 1995 was assessed. The amounts assessed have not been paid.
Petitioner’s 1997 Federal Income Tax Return
On July 16, 1999, the Philadelphia Service Center sent a
notice of deficiency for 1997 by certified mail to petitioner at
the Woodside address. That notice contained a mathematical
computation based on failure to calculate the alternative minimum
tax. Petitioner did not file a petition with this Court seeking
review of the 1997 deficiency. That deficiency was assessed on
December 20, 1999, and has not been paid. Petitioner
subsequently submitted an amended 1997 return.
Petitioner’s 1998 Federal Income Tax Return
Sometime before August 18, 1999, petitioner submitted an
unsigned Form 4868, Application for Automatic Extension of Time
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